OPINION AND ORDER
CEREZO, District Judge.
This is an action filed pursuant to sections 7401 and 7403 of the Internal Revenue Code of 1954, as amended, to foreclose tax liens in favor of the United States against taxpayer V & E Engineering & Construction Co., Inc. and upon the property now owned by codefendants Jorge Luis Berrios and Aida L. Cruz-Declet. This Court has jurisdiction pursuant to 28 U.S.C. sections 1340 and 1345 and 26 U.S.C. section...
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